On behalf of our 59 members, including our 17 members operating as Medicare Advantage Dual Eligible Special Needs Plans (D-SNPs) and 15 Medicare/Medicaid plans (MMPs) under the Dual Eligible Financial Alignment Demonstration, I am writing to express our strongest support for the legislation that you are marking up this week to address shortcomings in the operation of the Medicare Advantage program with regard to low-income, high need populations.
As you know, dual-eligible beneficiaries include the frail elderly, those with multiple chronic conditions, individuals with severe and persistent mental illness, Alzheimer’s disease, physical and developmental disabilities, and those suffering with the burdens of substance abuse. Many of these individuals have multiple medical, behavioral, and long-term care needs and need services from an array of specialized providers across the Medicare and Medicaid delivery systems. Dual-eligible beneficiaries are also low-income and their health and access to care can be complicated by socio-economic challenges.
Unlike many health plans, ACAP’s member safety net health plans serve exclusively full-benefit duals and as such are most impacted by inadequate and inaccurate rate setting resulting from the current risk adjustment system. In addition, the measures used as part of the STARS bonus system disregard the qualitative differences between full-benefit duals and all other Medicare Advantage plan enrollees. As such, safety net plans are disproportionately impacted by flaws in the MA payment and quality bonus systems.
That is why the slate of bills (H.R.s 2505, 2506, 2507, 2579) that you are considering are so important. Legislation to take into account the number of an enrollee’s chronic conditions, consider two-years of enrollee data, urging CMS to ensure the appropriateness of risk adjustment, and offering relief from plan termination resulting from the flawed STARS bonus program are welcome improvements to the program. In addition, giving health plans more time to evaluate and comment regarding the impact of the call letter and the publication of district specific information will help broaden and improve the public’s understanding of the program.
Again, thank you for your bipartisan leadership in looking for ways to improve the Medicare Advantage program for the poorest and highest-need beneficiaries and the plans dedicated to serving them. Please do not hesitate to contact me if I can be of any further assistance.